In Quern v. Jordan, the U.S. Supreme Court ruled that state officials could not be sued in federal court for retroactive monetary relief under Section 1983 of the Civil Rights Act of 1871. The case arose when a group of Illinois welfare recipients claimed they were wrongfully denied benefits and sought back payments from Gordon Johnson Jr., Director of the Illinois Department of Public Aid at that time. The court held that while states can be sued for prospective injunctive relief (i.e., to prevent future violations), they are immune from suits seeking retrospective damages due to sovereign immunity granted by the Eleventh Amendment unless explicitly waived or validly abrogated by Congress - which had not occurred here according to their interpretation.

In the dissenting opinion for Quern v. Jordan, Justice Brennan, joined by Justices Marshall and Stevens, argued that the majority's decision was inconsistent with previous Supreme Court rulings regarding 11th Amendment immunity. They contended that a state's sovereign immunity should not protect it from suits brought in federal court under Section 1983 of the Civil Rights Act when those suits seek prospective relief to prevent ongoing violations of federal law. The dissenters believed this case fell into an exception to sovereign immunity established in Ex parte Young (1908), which allows lawsuits seeking injunctions against state officials for ongoing violations of federal law. They criticized the majority’s interpretation as overly narrow and warned it could undermine enforcement of constitutional rights by insulating states from liability even when they are violating federal laws.